Nigel Howard, Vice President
U. S. Green Building Council
1015 18th St. NW, Suite 805
Washington, DC 20036

Date

Dear Mr. Howard,
I am writing in response to the US Green Building Council's Solicitation for PVC Stakeholders inviting comment on the proposed methodology for evaluating a PVC related credit within the LEED Rating System.

[Describe why your group is a stakeholder in this process, i.e., as a USGBC member, LEED practitioner, etc.]

The solicitation to stakeholders states a goal of analyzing evidence with regard to a "PVC-related" credit, but it is silent with regard to the underlying intent. LEED credits typically start with a definition of the "intent" of the proposed credit. The intent of the credit defines the primary data points to be considered in justifying a credit and verifying whether the requirements are appropriate to the goals. In the absence of a stated intent, the Council is proposing an enormously complex life-cycle analysis of not only PVC, but many alternative materials for selected applications. We are concerned that this approach threatens to make LEED unworkable if it is to be applied across the board for evaluations of multiple impact categories of all building materials.

We therefore support the recommendations of the Healthy Building Network, that a PVC-related credit be evaluated by the Council in relation to a specific intent which seeks to reduce the use and generation of highly toxic chemicals, and to promote end of use reuse and recycling of building materials. LEED standards should comply with the directive of the Stockholm Convention on Persistent Organic Pollutants, signed by the Bush Administration- along with officials from 90 other countries in May 2001, which commits signatories "to reduce the total releases [POPs] with the goal of their continuing minimization and, where feasible, ultimate elimination."

Please keep us informed of the Council's actions on this issue, and feel free to contact me if you have any questions or require further information.

Sincerely,